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` December 15, 2005
Mr. Robert S. Taylor
Executive Vice President, Treasurer and Chief Financial Officer
Superior Energy Services, Inc.
1105 Peters Road
Harvey, Louisiana 70058
Re: Superior Energy Services, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2004
Filed March 15, 2005
File No. 333-22603
Dear Mr. Taylor:
We have reviewed your Form 10-K for the Fiscal Year Ended December
31, 2004 and have the following comment. We have limited our
review
of your filing to those issues we have addressed in our comment.
Where indicated, we think you should revise your document in
response
to this comment. If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2004
General
1. We note you filed a Form S-4 to register your 8.875% Senior
Notes,
due May 2011 in July of 2001. In addition, we note you included
within the Form S-4 condensed consolidating financial information
related to certain subsidiary guarantors of the notes. Under Rules
3-
10(f) and 3-10(i)(8) of Regulation S-X, you are required to also
include subsidiary guarantor financial information and related
disclosures in the periodic reports you are required to file under
the Exchange Act. Please comply with these reporting
requirements,
or tell us why you believe they are no longer applicable.
Closing Comments
As appropriate, please amend your filing and respond to this
comment within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Jenifer Gallagher at (202) 551-3706 if you
have
questions regarding the comment on the financial statements and
related matters. Please contact me at (202) 551-3686 with any
other
questions.
Sincerely,
Karl Hiller
Branch Chief
Mr. Robert S. Taylor
Superior Energy Services, Inc.
December 15, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010